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RELEASE REPORT FOR DISCHARGE OF UNTREATED WATER TO INJECTION WELLS Phoenix–Goodyear Airport North Superfund Site Goodyear, Arizona Prepared for: Crane Co. 100 First Stamford Place Stamford, Connecticut 06902 November 2001 Project No. 6577 SDMS DOCID# 1142280
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RELEASE REPORT FOR DISCHARGE OFUNTREATED WATER TO INJECTION WELLSPhoenix–Goodyear Airport

North Superfund Site

Goodyear, Arizona

Prepared for:

Crane Co.100 First Stamford PlaceStamford, Connecticut 06902

November 2001

Project No. 6577

SDMS DOCID# 1142280

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November 19, 2001Project 6577.009

Ms. Andria Benner (SFD-8-2)Remedial Project ManagerUnited States Environmental Protection AgencyRegion IX75 Hawthorne StreetSan Francisco, California 94105-3901

Subject: Release Report for Discharge of Untreated Water ToInjection WellsPhoenix-Goodyear Airport North Superfund SiteGoodyear, Arizona

Dear Ms. Benner:

As requested in the August 24, 2001 letter from the U.S. Environmental Protection Agency toCrane Co., Geomatrix Consultants, Inc., has prepared this Release Report for the Discharge ofUntreated Water at the Phoenix-Goodyear Airport (PGA) North Superfund site in Goodyear,Arizona. The report incorporates and responds to the U.S. EPA’s November 1, 2001 letterregarding the conditional approval of the Draft Report.

Please feel free to contact either of the undersigned at (510) 663-4100 with questions orconcerns regarding this cost estimate.

Sincerely yours,GEOMATRIX CONSULTANTS, INC.

Douglas C. BablitchProject Engineer

Elizabeth Nixon, P.E.Project Manager

DCB/EAN/abr\\oak1\deptdata\Project\6000s\6577\Correspondence\Inject Well Release Report\Cover Letter9.19.01.doc

cc: Ms. Lou Minkler, Arizona Department of Environmental QualityMr. Phil Whitmore, CH2M HillDr. Anthony D. Pantaleoni, Crane Co.Mr. Al Bilzi, Environmental Venture GroupMr. Larry Meier, Arizona Department of Environmental QualityMr. Gordon Stephenson, Allen Stephenson Associates

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RELEASE REPORT FOR DISCHARGE OFUNTREATED WATER TO INJECTION WELLSPhoenix-Goodyear Airport

North Superfund Site

Goodyear, Arizona

Prepared for:

Crane Co.100 First Stamford PlaceStamford, Connecticut 06902

Prepared by:

Geomatrix Consultants, Inc.2101 Webster Street, 12th FloorOakland, California 94612(510) 663-4100

November 2001

Project No. 6577

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TABLE OF CONTENTS

Page1.0 INTRODUCTION ............................................................................................................ 1

2.0 GROUNDWATER TREATMENT SYSTEM DESCRIPTION ...................................... 1

3.0 DISCHARGE OF UNTREATED WATER TO INJECTION WELLS ........................... 23.1 PHASE 2/3 BLOWER MALFUNCTION ...................................................................... 23.2 DAMAGED RECIRCULATION VALVE FOR PHASE 1 SYSTEM.................................... 33.3 ESTIMATED DURATION AND QUANTITY OF DISCHARGE ........................................ 5

4.0 IMPROVEMENTS TO PREVENT FUTURE DISCHARGES....................................... 6

5.0 CONCLUSIONS .............................................................................................................. 7

FIGURES

Figure 1: Site Location MapFigure 2: Site PlanFigure 3: Process Diagram

APPENDIXES

Appendix A: August 24, 2001 Letter to Crane Co. From U.S. EPAAppendix B: May 5, 2000 letter to the U.S. EPA from Malcolm Pirnie, Inc.Appendix C: Photographs—Damaged Equipment Locations

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RELEASE REPORT FOR DISCHARGE OFUNTREATED WATER TO INJECTION WELLS

Phoenix–Goodyear Airport North Superfund SiteGoodyear, Arizona

1.0 INTRODUCTION

Geomatrix Consultants, Inc., (Geomatrix) has prepared this report on behalf of Crane Co.(Crane) to detail operations that resulted in the discharge of untreated and partially treatedwater from the groundwater treatment system at the Phoenix-Goodyear Airport (PGA) NorthSuperfund site in Goodyear, Arizona (Figure 1). This report responds to the U.S.Environmental Protection Agency (U.S. EPA) letter request of August 24, 2001 (attached asAppendix A). Geomatrix was retained by Crane to operate and maintain the treatment plant asof January 2001.

2.0 GROUNDWATER TREATMENT SYSTEM DESCRIPTION

The groundwater treatment system at the PGA North site was constructed in two phases,Phase 1 and Phase 2/3. Each phase consists of two extraction wells that convey groundwater tothe treatment system through underground pipelines. The Phase 1 system, constructed in 1994,treats water from onsite extraction wells EA-01 and EB-01. The Phase 2/3 system, constructedin 1997, treats water from offsite extraction wells EA-02 and EA-03. The extractedgroundwater is treated by packed column air strippers to remove the volatile organiccompounds (VOCs), primarily trichloroethene (TCE). The treated water is recycled to theSubunit A aquifer via five injection wells located near the southern property boundary. The airexiting the packed air stripper columns is treated through two vapor-phase granular activatedcarbon units before being vented to the atmosphere. Concentrated hydrochloric acid is used asa scale inhibitor for the air stripper towers.

The location of the extraction wells, treatment system, and injection wells are shown onFigure 2 (attached). The general equipment layout and process diagram for the Phase 1 andPhase 2/3 treatment systems is presented on Figure 3 (attached).

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3.0 DISCHARGE OF UNTREATED WATER TO INJECTION WELLS

In April 1998, concentrations of TCE began to increase in monitoring well MW-01, which wasthe upgradient monitoring location for the TCE plume in Subunit A. Concentrations roserelatively steadily over the next year and a half, at which time concentrations stabilized around200 micrograms per liter (µg/l) beginning in January 2000. Additionally, TCE was detected inthe nearby Park Shadows Irrigation Well (PSIW), with concentrations of 23 µg/l, 7.9 µg/l, and41 µg/l measured in March 1999, April 2000, and May 2001 respectively. Due to the relativelyclose proximity of MW-01 and PSIW to the injection wells used to discharge treated waterfrom the treatment plant, it is believed that the increase in TCE concentrations in the two wellsis related to the inadvertent discharge of untreated and partially treated water to theinjection wells.

Two treatment system malfunctions have been identified and corrected that likely resulted inthe discharge of partially or untreated groundwater to the injection wells. The first malfunctionwas the failure of the Phase 2/3 process air fan and the lack of interlocks to prevent the systemfrom continuing to operate without the fan operating, which occurred in 1998. The secondmalfunction is a damaged valve that allowed untreated process water to bypass the Phase 1treatment system and be discharged to the injection wells. The damaged valve was identified inFebruary 2001. The locations of the damaged equipment are presented on the attachedFigure 3. Both of these malfunctions have been corrected, and we expect the residual impact tothe Subunit A aquifer to diminish in the next 1 to 2 years. Details of the two malfunctions arepresented below.

3.1 PHASE 2/3 BLOWER MALFUNCTION

In March 2000, an investigation was initiated by Crane to assess the cause of the TCE trend inMW-01. Malcolm Pirnie Inc. (MPI), who operated the treatment plant at that time, prepared aletter report and submitted it to the U.S. EPA on May 5, 2000, which addressed the situation(attached as Appendix B). MPI reported that process air fan malfunctions for the Phase 2/3 airstripper system in 1998 had allowed water without complete treatment to be discharged toinjection wells positioned approximately 300 to 500 feet south of MW-01 (Figure 2). Thesemalfunctions, which reportedly occurred several times during 1998, were thought to be thecause of the TCE detected at monitoring well MW-01. MPI reported that at the time of themechanical malfunctions there was no interlock to shutdown the treatment system if either ofthe process air fans failed. As a result of not having the interlock, the system would continue

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pumping untreated water through the air strippers when the process air fans were inoperable,eventually discharging the untreated water to the injection wells.

The MPI letter report indicated that repairs to the process air fans and the addition of aninterlock had been completed by July 1998. The letter report stated that the blower system andinterlocks had operated apparently properly since July 1998. Based on the data provided in theMPI letter report, the maximum estimated quantity of water discharged during 1998 isapproximately 4 million gallons, containing approximately 85 pounds of TCE.

Our review of MPI system operations and maintenance records indicate that furthermodifications to the Phase 1 and Phase 2/3 systems to prevent similar discharges werecompleted in April 2000 by MPI. The additional modifications include adding an interlock toshut down the extraction wells in the event of low air flow through the air stripper towers andan interlock to shut down the appropriate extraction wells in the event of a process air fanmalfunction. These modifications had not been described in the May 5, 2000 letter report.Photographs showing the process air fan locations are attached as Appendix C.

3.2 DAMAGED RECIRCULATION VALVE FOR PHASE 1 SYSTEM

Geomatrix began operating the treatment plant in January 2001, at which time we conducted acomprehensive review of the equipment, operations, and control strategy for the Phase 1 andPhase 2/3 treatment systems. As a result of the review, Geomatrix discovered that the influentflow totalizer for the Phase 1 treatment system did not reconcile with the total flow rates fromthe Phase 1-extraction wells, indicating that influent water was bypassing the treatment system.Specifically,

• The combined flow rate from each of the Phase 1-extraction wells (EA-01 and EB-01) wasmeasured at 114 gallons per minute (gpm).

• The flow rate at the Phase 1 flow totalizer measured 56 gpm when the finish water(effluent) pump was not operating, approximately 58 gpm less than the total output of theextraction wells.

• The flow rate at the Phase 1 flow totalizer measured 121 gpm when the finish water(effluent) pump was in operation, approximately 7 gpm over the total output of theextraction wells.

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• The flow rate at the Phase 1 totalizers cycled between approximately 56 gpm and 121 gpmand coincided with the finish water pump cycling off and on (normal operation).

After the disparity in the flow totals was identified, Geomatrix personnel conducted furtherdiagnostic procedures to determine the cause. Geomatrix identified a faulty valve thatconnected the Phase 1 influent line with a recirculation line. The valve to the recirculation linewas closed during normal operations, preventing the untreated influent water from beingdischarged to the injection wells. However, the valve plate had deteriorated, creating a ¼-inchannular space between the plate and the valve seat that allowed water to leak past the closedvalve when the Phase 1 finish water pump was not operating. The butterfly-style valve likelywas damaged due to excessive or prolonged exposure to hydrochloric acid, which may havebeen caused by acid being injected during periods of system shutdown. The location ofthe recirculation line and the damaged valve are shown on Figure 3. Photographs showingrecirculation line and the damaged valves are attached as Appendix C.

The faulty valve intermittently allowed untreated influent water to bypass the treatment systemduring periods when the finish water (effluent) pump was not operating (the finish water pumpcycles on and off during normal operation). When the finish water pump was running, itproduced sufficient backpressure to prevent influent water from leaking past the damagedvalve. The discharge of untreated water likely was not identified previously through thesampling of effluent water because the effluent sample typically was collected while the finishwater pump was running (e.g., treated water was flowing in the effluent line). Based on fieldobservations, operational data, and the extent of the valve damage, we estimate thatapproximately 50 to 60 gallons per minute of groundwater was allowed to bypass the treatmentsystem approximately 50 percent of the operational time at the time the faulty valve wasidentified. This estimate equates to approximately 25 to 30 percent of the total flow passingthrough the Phase 1 system.

Geomatrix replaced the faulty valve immediately and removed the recirculation line completelyto prevent future discharges if the normally closed valve were to fail. Several other processvalves that had been damaged from acid exposure, but were not related to the discharge ofuntreated water, also were replaced. Improvements and modifications to the acid additionsystem were completed to prevent valves and other equipment from being exposed to acidduring system shutdowns. Additionally, procedures have been implemented to reconcile flowtotals each month, so that totalizer disparities can be identified quickly and accurately.

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A summary of system improvements implemented since January 2001 is provided inSection 4.0 of this report.

3.3 ESTIMATED DURATION AND QUANTITY OF DISCHARGE

Based on data trends from monitoring well MW-01 (TCE first detected in April 1998) andPSIW (TCE beginning to increase in March 1999), and on estimates of flow paths and traveltimes from the injection wells to MW-01 and PSIW, we estimate that injection of untreatedwater could have occurred as early as 1997. We have estimated travel times from the injectionwells to well MW-01 and to PSIW to be approximately 1 year and 2 to 3 years, respectively.A basic Winflow model, which is a two-dimensional analytical solution, was used to estimateflow paths and travel times. Historical effluent data from the Phase 1 treatment system includeoccasional detections of TCE, such as the detection of TCE at concentrations of 2.6 µg/l to4,400 µg/l between July and September 1999, indicating that discharges from the Phase 1system may have been occurring at least as early as 1999.

With the available information, we can not accurately measure or calculate the actual volume ofuntreated water that was discharged. However, we have made sets of assumptions to assesstwo possible discharge scenarios and associated order of magnitude discharge quantities. Thefirst scenario assumes that the valve began leaking in 1997, and that the condition of the valveprogressively worsened such that leakage increased linearly from 0 to 50 percent of the totalPhase 1 flow between May 1997 and February 2001. These assumptions lead to an estimate ofapproximately 20 million gallons of discharged water containing approximately 750 pounds ofTCE. The second scenario assumes that the valve began leaking in July 1999, and the leakageincreased linearly until February of 2001. Under these assumptions, the total quantity ofdischarged water is estimated to be 10 million gallons containing approximately 250 poundsof TCE.

It is not possible with the available information to know with certainty the proportion ofdischarged water that can be attributable to the process air fan/interlock malfunction of thePhase 2/3 system versus the faulty valve of the Phase 1 system. However, based on the aboveestimates and those provided by MPI for the process air fan malfunction in 1998, the totalquantity of discharged untreated and partially treated water could be on the order of 15 to25 million gallons. This range equates to approximately 5 to 10 percent of the total volume ofwater being injected to the Subunit A aquifer from mid-1997 through January 2001.

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4.0 IMPROVEMENTS TO PREVENT FUTURE DISCHARGES

In addition to the repairs to the damaged equipment discussed above, Geomatrix has institutedseveral procedures to provide checks and measures to minimize the possibility of futuredischarges and to protect against a discharge being undetected if one were to occur.A summary of the repairs, modifications, system improvements, and operational procedures issummarized in the table below.

ITEM DESCRIPTION RESULTRemove Phase 1recirculation line.

Geomatrix removed the Phase 1 recirculationline and replaced the damaged valveFebruary 6, 2001. The Phase 2/3 systemdoes not have a recirculation system.

Eliminated the possibility ofuntreated water bypassing thePhase 1 system even in the event ofa valve failure.

Replaced all pipelinevalves at the treatmentsystem.

Removed and replaced all the operationalvalves on both the Phase 1 and 2/3 treatmentsystems. Dedicated site technician alsoverifies the operation of each valve on aregular basis.

Proper control of process waterflow so that all influent water isprocessed through the treatmentsystems.

Reprogrammed theProgrammable LogicController (PLC).

Reprogrammed the PLC and modified thecontrol strategy to prevent damage toequipment or possible discharges due topartial or improper system shutdowns.Verified all system interlocks so that thesystems shutdown appropriately includingprocess air fans, extraction wells, injectionwells, acid addition system, and flooding ofthe treatment pad. Interlocks are verified aspart of the routine maintenance of thesystem.

The interlocks have preventedimproper system shutdowns anddamage to equipment by partialsystem shutdowns.Allows system operations to bemonitored remotely.Allows automatic notification ofproject personnel via numeric pageralarms in the event of systemmalfunctions.

Verify and reconcile allsystem flow totalizers.

The flow totalizers are reconciled eachmonth to verify that the system is operatingproperly.

System malfunctions are identifiedefficiently. Damaged equipment isrepaired as necessary. Improperdischarges are avoided.

Continuous ImprovementProgram.

A continuous improvement program hasbeen instituted for the groundwater treatmentsystems. The Geomatrix project team meetsmonthly to discuss operational andmaintenance issues. Possible solutions tooperational problems as well as improvementto the existing system are developed utilizingin-house expertise.

Operational issues are mitigatedregularly. The quality andperformance of the treatmentsystem is improved and thepossibility of a release isminimized.

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5.0 CONCLUSIONS

Two operational malfunctions at the PGA-North site groundwater treatment plant wereidentified as causing the inadvertent release of partially treated and untreated groundwater toinjection wells. As a result, TCE was introduced to the Subunit A aquifer at the south end of thesite. The malfunctions have been corrected, and operation and maintenance procedures havebeen improved to prevent discharges from occurring in the future. This report provided detailsof the operational malfunctions and corrective actions, and estimates release quantities. Thenature and extent of the impact to the Subunit A aquifer is being evaluated independently ofthis report.

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FIGURES

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ARIZONA

6577

1

SITE LOCATION MAP Phoenix-Goodyear Airport North Superfund Site

Goodyear, Arizona

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Base map from The Thomas Guide Street Guide and Directory, Metropolitan Area . Reproduced with permission granted by THOMAS BROS. MAPS®. This map is copyrighted by THOMAS BROS. MAPS®. It is unlawful to copy or reproduce all or any part thereof, whether for personal use or resale, without permission. All rights reserved.

0 0.5 Mile

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Project No.

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APPENDIX AAugust 24, 2001 letter to

Crane Co. fromU.S. EPA

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX

August 24,2001

Anthony Pantaleoni

75 Hawthorne Street San Francisco, CA 94105

Vice President, Environmental Health & Safety Crane Co. 100 First Stamford Place, Suite 400 Stamford, Connecticut 06902-6784

Subject: Follow-up Investigative Activities Regarding Contaminated Drinking Water Supply Wells in Goodyear, Arizona- PGA North Superfund Site

Dear Mr. Pantaleoni:

As initially discussed at the August 15, 2001 meeting in Phoenix, the purpose of this letter is to provide a technical framework to conduct further investigation of the contamination located southeast of the Unidynamics facility within Goodyear, Arizona. The Environmental Protection Agency (EPA) considers quick response and resolution of this issue by Crane Co. to be of high priority and necessary to protect public health and welfare. EPA and the Arizona Department of Environmental Quality (ADEQ) will continue to provide assistance and oversight. The two immediate investigative activities are to determine whether any conduit wells are spreading contamination and whether plant operational issues have been resolved to stop the spread of contamination.

EPA considers the identification of any conduit wells between the A and C subunits in the upper alluvial unit to be a critical first step to eliminate the threat from spreading of the groundwater contamination. Attached is a study, entitled "Contaminant Transport/Well Evaluation," prepared by Sharp and Associates for Goodyear Tire and Rubber Company at PGA South, which should be used as a reference for the work required at PGA North (Attachment 1). In light of the broader scope of the investigation, EPA is extending the deadline of August 30, 2001 to October 5, 2001, for submittal of the workplan requested in EPA's August 3, 2001 letter. The workplan should include a schedule and discussion of the methodology for completing a similar contaminant transport analysis for PGA North. The workplan should address the initial list of investigative activities identified at the August 15, 2001 meeting and during subsequent discussions (Attachment 2). The workplan also should encompass additional investigative and analytical activities (e.g., modeling) proposed by Crane.

In order to identify operational problems that may have contributed to the spread of contamination at the Phase UPhase II treatment facility, Crane Co. must submit a detailed release report, similar to the Close Out Report for the carbon release at the Plant 33A wellhead treatment facility. This Phase UPhase II Treatment Facility Release Report (Release Repor1) must describe

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all the historic operational and equipment problems that have occurred at the facility, not limited to the valve failure. The report also must discuss the timeframe and estimated quantities of released contaminants, and the measures and checkpoints implemented by Crane Co. to ensure that such an undetected release does not occur in the future. The Release Report must be submitted to EPA and ADEQ by WedResday, September 19, 2001.

As discussed in today's conference, PGA North is an agenda topic for the forthcoming Community Advisory Group (CAG) meeting scheduled for Monday, September, 24, 2001. Crane Co. should be prepared to give a short presentation, with visual diagrams, on the details of the valve failure and other operational problems at the CAG meeting.

Due to concerns expressed by the City of Goodyear regarding the credibility of the operation of the groundwater remediation plant, EPA will conduct an independent process engineering evaluation of the existing Phase I!Phase II treatment facility located at the Unidynamics facility. The results of this evaluation will be published in a final report, which will be provided to Crane Co. and made available to the public.

A follow-up meeting to discuss investigation progress is tentatively planned to be held in Phoenix ori September 25, 2001. The final date and a proposed agenda will be distributed by EPA in the near future.

If you have any questions, please give me a call at (415) 744-2361.

Sincerely,

4~ Andria Benner Remedial Project Manager

Attachments: I. "Contaminant TransporUWell Evaluation" Report (entire report sent by mail) 2. Initial List of Investigative Activities

cc: Lou Minkler, ADEQ Larry Meier, ADEQ AI Bilzi, Environmental Ventures, Inc. Mason Bolitho, ADWR Joel Wade, City of Goodyear Ruben Veloz, City of Goodyear Gordon Stephenson, Allen Stephenson Assoc. Bill Schulz, Park Shadows Country Homes Jerry Ellsworth, SunCor Matthew Garlick, LPSCO Elizabeth Nixon, Geomatrix Phil Whitmore, CH2M Hill

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APPENDIX BMay 5, 2000 letter to the

U.S. EPA fromMalcolm Pirnie, Inc.

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·----MALCOLM "IF!Nif, INC.

ll'liPE"PE:ND~N"t t:NYIAONMI!NT~\. ENc:ittNI:t:ff6, ~\.ar.,.,ll!;i:1ti. ~ CUNSULTANTH

May 5, 2000

Ms. Emily Roth U.S. Envirorunental Protection Agency Office of Superfund Programs 75 Hawthorne Street (H-7-2) San Francisco, CA 94105-390 l

Re: Assessment ofMW-1 TC:E Concentrations Phoenix-Goodyear Airport (PGA)-North.Superfund Site Goodyear, Arizona

Dear Ms Roth;

The purpose of thi~:~letter is a follow up to Anthony Pantaleoni of Crane Co. notifying you of this issue by telephone on March 23, 2000 and by Jetter dated March 24, 2000. Malcolm Pirnie, Inc. (MPI) conducted a review of systems operations data to identify potential causes for the detection ofTCE in upgradient well MW-1 at the Unidynamics facility in Goodyear, AZ. MPl a.lso interviewed staff to evaluate potential causes. MPl focused on the possibility that groundwater was recycled through the extraction and treatment system without complete treatment and re-injected into groundwater upgradient of well MW-1. The review indicated that the Phase II/III treatment system occasionally malfunctioned (blowers in .the air stripper were not operating) over a short time period and allowed groundwater to be recycled "without complete treatment". We emphasize ''without complete treatment" because we expect that some volatilization of the contaminants occwrcJ by the movement ofthe extracted groundwater through the air stripper system without the blowers operating. Our review has shown that the Phase 1 lreaimc:nl system has not malfunctioned.

TCE concentration!,) in MW-1 were generally below laboratory detection limits prior to April 1998. TCE was first detected above the MCL at a concentration of22ug!L in April 1998 and has continued to increase in concentration to 2 I Oug/L in January 2000. MW -1 is located approximately 300 to 500 feel in an apparent downgradienl direction oftlm:c injection wells and approximately 1,000 feet upgradient ofthe extraction wells.

When the blower malfunction was first noted in May 1998, a number of repairs to the treatment system were undertaken over a 40 day period to correct the problem. According to uur records, at worst case, the blower was down for no more than 15 days, and at best case, for as 1ew as 3 days. During these down periods, the Phase lJJlll system was operated at pumping rates that ranged betWeen 175 and 215 gallons per minute

lll\Jl)/wwW.jlirrm~ r:.:m1

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Ms. Emily Roth U.S. Enviromnental Protection Agency

May 5, 2000 P~:~gc2

(gpm). Approximately 66 percent ofthe extracted groundwater was recycled into injection wells IA-5 and lA-2, which are located upgradient of well MW-1. The Phas~ lliiil influent TCE concentrations (collected before the air·stripper) averaged about 2500ug!L during this period, However, some volatHization of contaminants occurred by movement through the air stripper and the resulting concentrations are believed to have been let>s than 2500ug/L. In July I 998, a new interlocking system was installed that would automatically shut the system down if n malfunction occurred. Since July 1998, the blower system and interlocks have operated apparently properly.

The relatively small volume of recycled (partially treated) groundwater is expected to be captured by the hydraulic containment system at the Van Buren Banier. MPI and S.S. Papadopulos and Associates, Inc. are presently reviewing groundwater elevations and swnpling data in the vicinity ofMW-1. the extraction wells, and the injection we11s to evaluate the effects of the groundwater mound on the uppennost aquifer at the southern end of the facility and surrounding area. We believe that the treatment system integrity was not compromised anu that the system continues to flush contaminants as intended.

If you hav~; any yuestions about these findings, please contact me at (713) 960-7420 or Steve Sagstad ofMalcolm Pimie, Inc. at (602) 231-5558.

Very Truly YuuTS,

R~ ~ S. Ly1ulMays,l'.E. J? . Vice President

cc: T. Pantaleoni, Crane Co. A. Bilzi, EVG P. Whitmore. CH2M Hill I'· Minkler, ADEQ K. Zeppctdlo, ADEQ G. Rogers, MPl PHO M. Derenbergcr, MPI PHO D. Tllckcr, MPl PHO S. Sag!>Lad, MPI PHD K. Goldstein, MPJ WHJ

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APPENDIX CPhotographs

Recirculation Line andDamaged Valves

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Damaged Recirculation Valve(Replaced 2001)

Recirculation Line(Removed 2001)

Discharge Line

S:\6

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Photograph 1. View of piping associated with the Phase 1 air stripper and recirculation line. The damaged valve was replaced and the recirculation line was removed during February 2001.

Photograph 2. View of damaged recirculation valve replaced during February 2001. See photo 1. The screwdriver is shown to identify the gap in damaged valve.

Phase 1InfluentPhase 1Influent

Recirculation Line(Removed 2001)

Discharge Line

Damaged Recirculation Valve(Replaced 2001)

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Recirculation Line(Removed 2001)

Phase 1 Effluent LinePhase 1 Effluent Line

Damaged valve(Replaced 2001)

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Photograph 3. View of discharge line and recirculation line.

Recirculation Line(Removed 2001)

Damaged valve(Replaced 2001)

Photograph 4. Additional damaged valve at Phase 1 Effluent line. See Photo 3.

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1

Nancy Nesky

From: Koehne, Stephanie <[email protected]>Sent: Monday, February 27, 2012 5:45 PMTo: Jeffers, Paul; Nancy Nesky; '[email protected]'Cc: '[email protected]'; '[email protected]'; '[email protected]';

'[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; Ailiang Gu; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; Sandra Rode ([email protected]); Richards, Kate; Yang, Gao; [email protected]; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; Douglas Fisher; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]'; Daus, Tony; '[email protected]'; '[email protected]'; '[email protected]'; Minnier, Gwen E; Panday, Sorab; Patel, Nimisha; '[email protected]'; '[email protected]'; '[email protected]'; 'Jody Lee Mack'; 'Patrick Hunnewell'; [email protected]; Corkery, Emily; '[email protected]'

Subject: PGA-North February 8, 2012 Action Item List #3Attachments: Release_Rpt_Injection_Well.pdf

Ms. Brown:

In accordance with the February 8, 2012 PGA-North Action Item List, Item #3; attached, please find the Summary Report on Unintentional Release of Untreated Water from MTS.

Please contact me if you have any questions. Regards, Stephanie Stephanie Lyn Koehne, MBA  Project Manager AMEC Geomatrix, Inc. 8777 East Via de Ventura, Suite 396 Scottsdale, Arizona 85258   Phone - 480-348-1244 Direct Line - 480-348-1293 Work Cell - 480-734-6279 Personal Cell - 480-323-9924 Fax - 480-348-1245 

 

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